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March 6, 2022

U.S. International Tax This Week for March 4

Ernst & Young's U.S. International Tax This Week newsletter for the week ending March 4 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.


President Biden gave his first State of the Union address on 1 March during which he called on Congress to enact many of the individual provisions of his proposed Build Back Better (BBB) plan, although not mentioning BBB by name. The President tried a different approach given the country's current economic climate, making the argument that the provisions would reduce inflation by lowering costs and reducing the deficit. The President also targeted tax fairness, saying the Administration would work to close what he called corporate tax loopholes. "The one thing all Americans agree on is that the tax system is not fair. We have to fix it." He also made a pitch for a 15% minimum corporate tax rate.

The next day, Senator Joe Manchin suggested that he could support a substantially pared down budget reconciliation package that tackles reforming the tax code and reducing the cost of prescription drugs, if most of the revenue raised is used for new climate proposals and reducing the deficit and inflation. Senator Manchin was quoted as saying he does not have any concrete proposals, only the outline of what he could support, and said he had had informal discussions with the White House. The Senator further reiterated prior comments made in the past in regard to reconciliation: "I'm just saying reconciliation is for getting your financial house in order."

There reportedly was considerable dissatisfaction with Senator Manchin among progressive Senate Democrats following his statement about BBB after the State of the Union address. His statement is seen as casting significant doubt as to the future of most of the social spending in the original bill.

The press this week quoted Senate Democrats as saying they are considering the possibility of taking action with regard to the 1992 US-Russia income tax treaty, as a response to the ongoing situation in Ukraine. Treasury reportedly declined to comment on the possibility of terminating the tax convention.

Upcoming Webcasts

Transparency in the sharing economy: What to know about DAC7 and beyond (March 24)
During this EY Webcast, Ernst & Young professionals will discuss the global adoption of tax reporting rules for digital platforms, including OECD’s Model Rules, EU’s tax automatic exchange of information directive known as DAC7 and the UK’s hybrid implementation.

Recent Tax Alerts


— Mar 02: Kenya High Court invalidates VAT Regulations, 2017 and declares maritime agency services provided to nonresident shippers should qualify as exported services (Tax Alert 2022-0338)


— Mar 01: Hong Kong 2022 - 23 Budget Proposal discussed (Tax Alert 2022-0344)

— Feb 25: Hong Kong announces 2022-23 budget (Tax Alert 2022-0327)

Canada & Latin America

— Mar 03: EY Canada's Tax Matters @ EY for March 2022 (Tax Alert 2022-0356)

— Mar 03: Peru's President amends Tax Code and registration process for the Tax ID Registry (Tax Alert 2022-0355)

— Feb 25: Prince Edward Island budget 2022-23 discussed (Tax Alert 2022-0329)

— Feb 25: Alberta budget 2022–23 discussed (Tax Alert 2022-0325)


— Mar 03: European Commission proposes new Directive on corporate sustainability due diligence aimed at establishing legal accountability for global value chains (Tax Alert 2022-0353)

— Mar 02: Czech Republic introduces special immigration provisions for Ukrainian nationals (Tax Alert 2022-0352)

— Mar 02: Luxembourg Tax Authority clarifies application of real estate levy including reporting requirement for all Luxembourg corporate investment vehicles (Tax Alert 2022-0348)

— Mar 01: Updates on BEPS 2.0 project from OECD Tax Talks and G20 Finance Ministers meeting (Tax Alert 2022-0341)

— Mar 02: European Parliament provides recommendations on EU Carbon Border Adjustment Mechanism (Tax Alert 2022-0340)

— Mar 02: Italian Tax Authorities issue resolution on Mandatory Disclosure Rules (Tax Alert 2022-0339)

— Feb 25: EU Member States adopt revised list of non-cooperative jurisdictions for tax purposes (Tax Alert 2022-0326)

IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2022-10Internal Revenue Bulletin of March 7, 2022

Additional Resources

Ernst & Young Client Portal, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

EY/Passport. EY/Passport is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

Because the matters covered herein are complicated, U.S. International Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.